- 44 - documentation to support the business deductions claimed on the return. There is no record evidence to support that assertion, and, even if there were, we are not persuaded that petitioner’s preoccupation with establishing a new business would constitute reasonable cause for failure to file timely his 1999 return. See Polsby v. Commissioner, T.C. Memo. 1998-459; Estate of Bevan v. Commissioner, T.C. Memo. 1989-256. We uphold respondent’s determination that petitioner is liable for the addition to tax under section 6651(a)(1) for failure to file timely his 1999 return. The correct amount of the addition to tax must be calculated as part of the Rule 155 computation. To give effect to the foregoing, Decision will be entered under Rule 155.Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44
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